ALTIMARI, Circuit Judge:
Connecticut National Bank ("executor" or "CNB"), the executor of John W. Leahy's ("John's") estate, appeals from a judgment entered in the United States District Court for the District of Connecticut (Peter C. Dorsey, Judge), finding that the estate was not entitled to a $1,485,882 income tax refund for alleged overpayments of capital gains taxes made to the United States government for the tax year 1982. This appeal primarily concerns...
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